375 Slane Chapel Road, LLC v. Stone County, Missouri, No. 21-3367 (8th Cir. 2022)Annotate this Case
Plaintiffs own 375 Slane Chapel Road, LLC (“375”), a limited liability company that owns and operates a substantial vacation home adjacent to Table Rock Lake in Stone County, Missouri. When Plaintiffs' personal use of the home declined, 375 applied in October 2020 for a conditional use permit (“CUP”) to rent out the property to short-term renters on platforms such as Airbnb. The Board of Adjustment voted 3-0 to reverse the Planning & Zoning Commission’s decision and deny 375 a CUP. 375 filed separate actions in state and federal court to overturn the Board of Adjustment’s decision. Defendants promptly moved to dismiss this lawsuit, arguing, as relevant here, that 375’s federal claims are “barred by the Younger abstention doctrine.” Invoking Younger v. Harris, 401 U.S. 37 (1971), the district court granted the motion.
The Eighth Circuit reversed, concluding that the district court misinterpreted the “exceptional circumstances” warranting Younger abstention. The court explained that the district court’s definition of Category 3 shares the flaw in relying exclusively on the Middlesex factors identified by the Supreme Court in Sprint -- it “would extend Younger to virtually all parallel state and federal proceedings . . . where a party could identify a plausibly important state interest.” The two cases cited by NOPSI as examples of Category 3 make clear that its focus is institutional -- “the state courts’ ability to perform their judicial functions” -- not simply the State’s interest in enforcing a particular court order. Therefore the district court erred in abstaining under Younger.